Documents

The Zionist Organization of
America (ZOA), a U.S. subsidiary of the World Zionist Organization, was
organized in Pittsburgh in 1918. The ZOA was invited by the U.S.
Department of State to begin registering as the foreign agent of the
World Zionist Organization immediately after passage of the 1938 Foreign
Agents Registration Act (FARA). The ZOA refused, citing it was an
American organization working to establish a Jewish homeland in
Palestine, an objective supported by congressional resolutions.
The ZOA cited funding flows to its affiliate organizations, rather than
receipt of international funding. ZOA refused to register on the
grounds that it did not receive any subsidies from the World Zionist
Congress.

In July of 1941, the Near East
Division of the State Department again pushed for ZOA registration
arguing that the ZOA was a subsidiary corporation despite the flow of
funding. The State Department had sent an employee on an
undercover visit to ZOA offices, determining it was an overtly
political—as opposed to religious—organization and therefore not subject
to the FARA exemptions available to religious entities such as the Vatican. The State Department found
that ZOA was "subject to the direction" of the WZO and ordered the ZOA
to register. ZOA again refused, stating that as a New York
corporation is was merely an "affiliate" of the WZO.

The US Department of Justice, upon
taking over FARA enforcement, internally found that the ZOA was
subject to registration, noting in June of 1943 that the "...threat of
prosecution or actual prosecution by the Department of Justice for
failure to register seems to be the only remaining effective action.
But I doubt that such action would be warranted under the circumstances
at this time..." In October, the OSS (intelligence agency precursor to the CIA)
provided input on Zionist activities overseas indicating registration, but by November
some Justice
Department employees began detecting political pressure. "..the
pressure was on somewhere in the government... it would be unwise to do
anything further...under the circumstances do not desire for the moment
to write to the Zionist Organization of America..."

On February 25, 1948 the DOJ
issued another FARA order to the ZOA citing undue delays in responding
to a matter "under consideration for some time." With US recognition
of the state of Israel immanent, the Attorney General ordered that the registration
question be delayed for 60 days. By May, frontline DOJ employees were
hearing rumors that a high DOJ official privately told ZOA representatives that
registration would not be necessary, and that they need not "fear
prosecution. " Despite ongoing FBI reports of PR and political
activities by the ZOA, the Justice Department agrees to quash the
registration order if the ZOA alters some of its corporate articles
defining relationships with the WZO. As noted by the head of the
FARA section, the DOJ never actually confirmed whether the exonerating changes to the WZO/ZOA
constitutions are ever made.

Certificate of Merger -Middle East Network
into the Zionist Organization of America

These files were obtained from the US Department of Justice Records
Group 60 held at the National Archives and Records Administration at
College Park, MD via a Freedom of Information Act request filed on
September 8, 2011.

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